Doctor Conor Comely specializes in surgeries that are not me…

Doctor Conor Comely specializes in surgeries that are not medically necessary such as face lifts. Since most of the procedures Doctor Comely performs would not be covered under insurance, he only accepts credit cards for payment and does not bill insurance. Riley Rusty, a potential patient, looks online for a doctor to perform a facelift and finds Doctor Comely’s website. When Riley visits Doctor Comely’s office, Riley does not receive a privacy notice with his initial paperwork. Riley asks Doctor Comely for a copy of the privacy notice and is told that the office does not maintain a privacy notice. Is it likely that Doctor Comely has violated HIPAA?